A notice regarding a revision to the WeXpats Privacy Policy

As of 2024/2/13, we have revised the following.

Article 1: Collection of Personal Information when Registering to Use WeXpats

The following has been added regarding the collection of personal information when registering to use WeXpats.

1. When registering to use the WeXpats service, Leverages collects your name, email address and profile photo from Meta or Google using the social login function with your consent. Leverages also collects information about your nationality, address, date of birth, age, gender, telephone number, personal background, qualifications held, status of residence, and Japanese language skills during and after registration through how you fill out the forms on the WeXpats site. You are required to provide this Personal Information in order to use the services provided by WeXpats for matching with companies.

2. Leverages will provide your Personal Information collected as stipulated in Paragraph 1 to specified companies for which you wish to be employed, with your prior consent. The purpose of this is to provide information necessary for the company to determine whether or not to hire you and to contact you regarding your employment or non-acceptance. Leverages will enter into an agreement with the company to ensure that the company does not use your Personal Information for any purpose other than those listed above.

3. Leverages will use your name and e-mail address from your Personal Information collected as stipulated in Paragraph 1 to send e-mails to you with your consent. E-mails will be sent for the following purposes:

(1) To provide you with information about job openings that you can apply for on WeXpats. (2) To provide information about new WeXpats services or campaigns that are beneficial to you. (3) To provide you with information about housing, insurance, accommodation, transportation means and other information that may be useful to you when visiting or living in Japan related to using WeXpats. (4) To notify you of any changes in the content of WeXpats services. (5) To notify you about the creation of articles provided by WeXpats in order to recruit collaborators from among our users. (6) To request your cooperation in questionnaires regarding WeXpats' services or employment and working conditions in Japan for the purpose of providing you with information about WeXpats' services that is more suitable to your needs. (7) To request your cooperation in questionnaires regarding WeXpats' services or employment and working conditions in Japan for the purpose of tailoring the specifications of the website and other systems that provide WeXpats to better meet your needs.

4. Leverages will use your name, telephone number and email address from your Personal Information collected as stipulated in Paragraph 1 to respond to your inquiries to us regarding WeXpats services.

5. Leverages may use your name, address, and telephone number from your Personal Information collected as stipulated in Paragraph 1 to send you gifts and other special offers.

6. Leverages may use your Personal Information collected as stipulated in Paragraph 1 to as statistical data in a format that does not identify your personal information, with your prior approval.

7. Leverages may entrust all or part of the handling of your Personal Information collected as stipulated in Paragraph 1 to a third party to the extent necessary for us to achieve the purpose of use.

Article 34: Revision of the Privacy Policy

The following was changed in the revision of the privacy policy.

Before revision:legal/translations.content.ju_before

After revision:When we revise this Privacy Policy, we will announce the revision, date of revision and the revised content on the WeXpats website or via e-mail.

Terms of Use

These WeXpats Terms of Use (hereinafter, these Terms) establish the conditions of provision of this Service, and the rights and obligations of the Company and those of its Registered Users, as defined below. In order to utilize this Service, it is necessary to read and agree to the entire contents of these Terms.

Article 1 (Application)

1. The purpose of these Terms is to establish the conditions of provision of this Service, and the rights and obligations between the Company and its Registered Users, and applies to everything related to the use of this Service.

2. If an explanation of this Service outside these Terms differs from the contents of these Terms, the provisions of these Terms shall prevail.

Article 2 (Definitions)

  • ‘Service Usage Contract’ means these Terms and all rule usage contracts concluded between the Company and the Registered User.

  • ‘Intellectual Property Rights’ mean copyrights, patents, utility model rights, design rights, trademarks and any other intellectual property rights (including the acquisition of those rights and the right to apply for registration regarding those rights).

  • ‘Posted Data’ means contents posted or sent by the Registered User using this Service (including but not limited to words, images, movies and other data).

  • ‘The Company’ means Leverages Co., Ltd.

  • ‘The Company’s Website’ means websites operated by the Company under the domains ’we-xpats.com’ or ‘wexpats.com’ (including the Company’s Websites of which, for whatever reason, domains or contents have been altered).

  • ‘Registered User’ means an individual or corporate user who is registered to use this Service based on the provisions stipulated in Article 3.

  • ‘This Service’ means the service provided by the Company under the name WeXpats (including services of which, for whatever reason, names or contents have been altered) and is the general term for all related services.

  • ‘User’ means all users of the Company’s Service, including Registered Users.

  • Article 3 (Registration)

    1. Those who wish to use this Service must agree to strictly abide by these Terms in their entirety. Additionally, those who wish to use a part of the Services, may apply to use this Service by providing certain information determined by the Company (hereinafter, ‘Registration Details’) in a way prescribed by the Company.

    2. An application for registration issued by an applicant (hereinafter, ‘Registration Applicant’) based on the provisions of the preceding article, shall be judged by the Company according to its criteria and, in the case of registration being acknowledged, the Registration Applicant shall be notified. For the avoidance of doubt, registration as a Registered User is complete once the Registration Applicant has been notified by the Company, as specified in this article.

    3. Once registration has been completed as stipulated in Paragraph 2 of this article, the Service Usage Contract between the Registered User and the Company is established, and the Registered User can use this Service according to these Terms.

    4. If a Registration Applicant agrees to the contents of the terms of use established by a business partner of the Company via a separate application, application is complete.

    【Business partner of the Company】

    5. If, for any reason, any of the following items apply to a Registration Applicant, the Company may refuse registration or re-registration. In such a case, there are no obligations to disclose the reason.

  • If all or part of the Registration Details provided to the Company are false, erroneous or incomplete
  • If a Registration Applicant is a minor, adult ward, or person under curatorship or assistance, for which approval has not been obtained from such applicant's legal representative, guardian, curator or assistant
  • If the Company deems a Registration Applicant to be an antisocial force (organized crime syndicate, member of organized crime syndicate, right-wing organization, anti-social force or equivalent. The same shall apply hereinafter.) or to be interacting with or involved in any kind of antisocial force through cooperation or contribution regarding the maintenance, operation or management of an antisocial force by means of funding or the like.
  • If the Company deems a Registration Applicant to have, in the past, breached a contract with the Company, or to be linked with such a breach
  • If a Registration Applicant is a recipient of measures stipulated in Article 10
  • If the Company deems registration inappropriate for any other reason
  • Article 4 (Accuracy of Registration Details)

    1. The Registered User shall provide the Company with accurate personal information, free from deficiency or inconsistency. If any objection, claim, or demand is raised by a third party due to inaccurate and/or deficient or inconsistent information provided by the Registered User, they shall deal with it at their own expense and responsibility, and will guarantee not to cause any inconvenience to the Company.

    2. If there are any changes to the Registered User’s Registration Details, the said User shall, without delay, notify the Company of the relevant details in a method prescribed by the Company.

    Article 5 (Management of passwords and User ID)

    If the Company issues a member with a password and User ID in relation to this Service, the User shall be responsible for the use and management of the said password and User ID. Under no circumstances shall they be used by or passed on to a third party.

    Article 6 (Provision of service)

    1. The purposes of this Service are as follows:

    ①Exchange of information between Users in a question and answer format; the opportunity for Users to gather and access information, and the provision of the environment in which to do so

    ②Collation of information received in Registered Users’ application contents and information received from user enterprises, as well as the provision of information based on the results of that collation

    ③Proxy application procedures

    ④Implementation of matching consultation via telephone or interview

    ⑤Reference and provision of job offer information

    ⑥Provision of the opportunity to attract Registered Users to interview and recruit selection offered by user enterprises

    ⑦Provision of businesses concomitant with the preceding item

    ⑧Any other services that the Company deems beneficial to Users

    2. The Company may add new services to this Service, or alter the service without notifying Registered Users in advance.

    3. This Service operates in cooperation with multiple other website services, and contents posted on this site may, under certain conditions, be published on other websites.

    Article 7 (Prohibited matters)

    When using this Service, a Registered User must not behave in a way that corresponds to any of the following actions or is deemed by the Company to correspond to any of the actions.

  • Actions that violate the law or are related to criminal activity
  • Scams or intimidation against the Company, other Registered Users of this Service, or a third party
  • Actions that violate public order and/or standards of decency
  • Actions that infringe upon the Intellectual Property Rights, image rights, right to privacy, honor and any other rights or profits of the Company, other Registered Users of this Service, or a third party
  • Actions that put excessive load on this Service’s network or system
  • Actions that may interfere with the management of this Service
  • Actions involving unauthorized access or attempted unauthorized access of the Company’s network or system
  • Impersonating a third party
  • Sharing a User ID with another person
  • The act of one person possessing multiple User IDs
  • Using the User ID or password of another Registered User of this Service
  • Promotion, advertisement, solicitation or sales that utilize this Service without the prior permission of the Company
  • Actions aimed at collecting the information of other Users of this Service
  • Actions that cause disadvantage, damage or discomfort to the Company, other Registered Users of this Service, or a third party
  • Actions that conflict with all rules concerning use of this Service and posting on the Company’s Website
  • Patronage of an antisocial force
  • Actions that induce or facilitate, either directly or indirectly, behavior stipulated in the preceding item
  • The act of utilizing site management or technical information obtained through the use of this Service to provide a similar service
  • The use of this Service to send to the Company, or another User of this Service, data that corresponds to or is deemed by the Company to correspond to any of the following:
  • Data that includes expressions of violence or cruelty
    Data that includes computer viruses or other harmful computer programs
    Data that includes expressions that may damage the honor or credibility of the Company, other Registered Users of this Service, or a third party
    Data that includes obscene expressions
    Data that includes expressions that may increase or promote discrimination
    Data that includes expressions that increase or promote self-harm or suicide
    Data that includes expressions that increase or promote the improper use of drugs
    Data that incudes antisocial expressions
    Data that seeks to spread the information of a third party, via chain mail and the like
    Data that includes expressions that may cause discomfort to others
    Data for the purpose of becoming acquainted with people of the opposite sex

  • Any other acts that the Company deems inappropriate
  • Article 8 (Suspension of this Service)

    1. In any of the following cases, the Company reserves the right to discontinue or suspend this Service in its entirety or in part, without advance notification to Registered Users.

    ・In the case of emergency inspection or maintenance work being carried out on computer systems related to this Service
    ・In the case of this Service being unmanageable due to computers or Internet connections being accidentally terminated as a result of a force majeure such as an earthquake, lightning strike, fire, wind or flood damage, power outage or natural disaster
    ・Other cases in which the Company deems it necessary to discontinue or suspend this Service

    2. The Company cannot be held responsible for any loss or damage caused to Registered Users as a result of measures carried out by the Company based on this article.

    Article 9 (Attribution of rights)

    1. All Intellectual Property Rights regarding the Company’s Website and this Service are attributable to the Company or those licensed by the Company; the license to use this Service based on these Terms does not mean a license for the Intellectual Property Rights of the Company or those licensed by the Company, in relation to the Company’s Website or this Service.

    2. Registered Users shall state and guarantee to the Company that they possess the legal rights to Posted Data and other things posted or sent, and that Posted Data does not infringe upon the rights of a third party.

    3. With regard to Posted Data, the Registered User grants the Company license regarding global, non-exclusive rights free of charge, for sublicensable or transferable use, to duplicate, edit, rearrange, publish, reprint, publicly transmit, screen, exhibit, offer, sell, transfer, loan, translate, adapt or distribute, as well as license related to the rights of the current copyright holder concerning derivative work (including commercial use and the rights of Article 21 or 28 of the Copyright Act).

    4. For the purpose of improvement/publicity/promotion of use of the site, Registered Users shall permit the distribution of metadata and edited contents of posts by other Users, as well as their publication on the Company’s site or a site with which the Company is affiliated.

    5. Registered Users shall agree not to exercise the author’s moral rights with regard to the Company or those with rights inherited from or licensed by the Company.

    Article 10 (Cancellation of registration)

    1. If, for any reason, any of the following apply to a Registered User, the Company reserves the right to edit or delete Posted Data, temporarily suspend the said Registered User’s use of this Service, cancel the registration of a Registered User, or cancel the Service Usage Contract without prior notification or warning.

  • In the case of violation of any of the articles in these Terms
  • In the case of falsehoods being identified in the Registration Details.
  • If payment stops or payment is not possible, or if bankruptcy proceedings, civil rehabilitation proceedings, receivership proceedings or special liquidation proceedings begin, or if there is a petition to start such procedures
  • In the case of this Service not being used for six months or more
  • If a response to an inquiry from the Company, or other contact requiring a response, is not received within 30 days
  • Cases to which Article 3, Paragraph 5 applies
  • Any other cases in which the Company deems use of this Service, registration as a Registered User, or continuation of the Service Usage Contract, inappropriate
  • 2. If any of the reasons in the preceding paragraph apply, the Registered User will naturally lose the benefit of any deadline for the payment of any outstanding debts owed to the Company, and must settle them all immediately.

    3. The Company cannot be held responsible for any loss or damage caused to Registered Users as a result of actions taken by the Company based on this article.

    Article 11 (Cancelation of membership)

    1. Registered Users may withdraw from this Service and cancel their registration as a Registered User by notifying the Company in the method prescribed by the Company.

    2. On cancellation of membership, if there are any outstanding debts owed to the Company, the Registered User will naturally lose the benefit of any deadline for their payment, and must settle all debts owed to the Company, immediately.

    3. Matters regarding the handling of personal information after cancellation of membership are stipulated in the provisions of Article 17.

    Article 12 (Alterations to and termination of the contents of this Service)

    1. The Company reserves the right to alter the contents or terminate the provision of this Service at the Company’s own convenience. In the case of terminating its provision, the Company shall notify Registered Users in advance.

    2. The Company shall not be liable for any loss or damage caused to the Registered User as a result of measures taken by the Company based on this article.

    Article 13 (Disclaimer of guarantees)

    1. The Company cannot guarantee that this Service is compatible with the Registered User’s specific purposes, nor that it meets expectations regarding function, commercial value, accuracy or usefulness. Neither can it guarantee that the Registered User’s utilization of this service will comply with laws or internal rules of certain economic or industrial groups applicable to the Registered User, or that no problems will occur.

    2. The Company cannot be held responsible for actions or results based on information acquired by Registered Users from this Service (including information recorded on this Service, external information such as books and the like that are introduced, and information found on links).

    3. The Company cannot be held responsible for websites accessed by Registered Users via links. Having a link does not mean the linked company is affiliated with the Company, or that it trades with or has any other connections with the Company.

    Article 14 (Elimination of antisocial forces)

    Registered Users shall declare that the term antisocial force (organized crime syndicate, member of an organized crime syndicate, former member of an organized crime syndicate who has not been a member for less than 5 years, associate member of an organized crime syndicate, company affiliated with an organized crime syndicate, racketeer group, group engaging in criminal activities under the pretext of conducting social campaigns, a crime syndicate specializing in intellectual crimes and the like, or equivalent people) does not apply to them, and that they do not engage in illegal activities such as violent behavior, scams, threatening behavior, disruption of business or the like, nor will they do so in the future. If this declaration is violated, the said User shall accept the termination of the provision of this Service without objection.

    Article 15 (Disclaimer)

    1. The Company shall not be liable for compensation concerning the Company’s provision of this Service being interrupted, suspended, terminated, unavailable or altered; or for the deletion or disappearance of messages or information sent to this Service by a Registered User; or for the disappearance of a Registered User’s registration data, the disappearance of data, equipment failure or damage, or any other damage suffered by a Registered User utilizing this Service (hereinafter, ‘User Damage’).

    2. Even if, for some reason, the Company is found to be responsible, the Company shall not be liable for compensation for User Damage that exceeds the amount paid to the Company by the Registered User in the past 12 months, nor shall it be liable for compensation regarding incidental damage, indirect damage, special damage, future damage or damage incurred from loss of profit.

    3. The Company has no obligation to manage or delete data posted on this Service.

    4. The Company cannot be held responsible for any transactions, contact or conflicts that occur between a Registered Use and other Registered Users or a third party in relation to this Service or the Company’s Website.

    Article 16 (Confidentiality)

    Information related to this Service that is not publicly known and has been disclosed to the Registered User confidentially by the Company shall be treated as confidential by the Registered User unless the Company provides prior written consent.

    Article 17 (Handling of personal information)

    The Company’s handling of the Registered User’s personal information shall be done in accordance with the provisions of ‘Privacy Policy’, and the Registered User consents to the Company handling the Registered User’s personal information accordingly.

    Article 18 (Liability for damages)

    If a Registered User violates any of the matters stipulated in these Terms and causes damage to the Company, persons concerned, or a third party, the Registered User shall be liable to compensate for those damages.

    Article 19 (Alterations to these Terms)

    The Company reserves the right to alter these Terms. If the Company alters these Terms, it shall notify the Registered User of the applicable altered contents, after which, if the Registered User utilizes this Service or does not cancel the registration within the period determined by the Company, it shall be deemed that the Registered User consents to the alterations in these Terms.

    Article 20 (Contact/notification)

    Inquiries regarding this Service, or any other contact or notification by a Registered User to the Company, or notification regarding alterations to these Terms or any other contact from the Company to the Registered User, shall be done in the method prescribed by the Company.

    Article 21 (Transfer of status under the Service Usage Contract)

    1. Registered Users shall not assign, transfer, set as collateral or otherwise dispose of the status under the Service Usage Contract, or the rights and obligation based on these Terms, to a third party without the prior written consent of the Company.

    2. If the Company transfers business related to this Service to another company, the status under the Service Usage Contract, the rights and obligations based on these Terms, and the Registered User’s Registration Details and other customer information can be transferred to the transferee in this business transfer. The Registered User shall consent in advance to the transfer stipulated in this paragraph. Furthermore, the business transfer stipulated in this paragraph is not limited to normal transfer of business but also includes corporate divestiture and all other kinds of business transfers.

    Article 22 (Separability)

    If any of the articles in these Terms, or a part of them are judged to be invalid or unenforceable according to the Consumer Contract Act or any other laws, the remaining regulations or parts other than those judged to be invalid or unenforceable shall continue to be valid.

    Article 23 (Governing laws and court of competent jurisdiction)

    1. These Terms and the Service Usage Contract shall be governed by Japanese law. Furthermore, if the sale of goods occurs in this Service, it is agreed that application of the United Nations Convention on Contracts for the International Sale of Goods shall not apply.

    2. Any disputes arising from or related to these Terms or the Service Usage Contract shall be subject to the exclusive jurisdiction of the Tokyo District Court or Tokyo Summary Court in the first instance.

    These Terms are provided in Japanese as the original text, and translated into other languages according to the region in which you reside.

    Date of implementation: February 26, 2019

    Date of revision: April 1, 2022

    WeXpats Privacy Policy

    Leverages Co., Ltd. (hereinafter referred to as "Leverages, " "we, " "us, " or "our") has established the following privacy policy regarding the processing of Personal Information in the service WeXpats (hereinafter referred to as "WeXpats") operated by Leverages. Leverages declares that it will comply with the Act on the Protection of Personal Information, the General Data Protection Regulation (hereinafter referred to as the "GDPR"), and the California Consumer Privacy Act (hereinafter referred to as the "CCPA"). When the GDPR is applied, the term "Personal Information" shall be replaced with the term "Personal Data".

    Chapter 1: Processing of Personal Information and its Purpose

    Article 1: Collection of Personal Information when Registering to Use WeXpats

    1. When registering to use the WeXpats service, Leverages collects your name, email address and profile photo from Meta or Google using the social login function with your consent. Leverages also collects information about your nationality, address, date of birth, age, gender, telephone number, personal background, qualifications held, status of residence, and Japanese language skills during and after registration through how you fill out the forms on the WeXpats site. You are required to provide this Personal Information in order to use the services provided by WeXpats for matching with companies.

    2. Leverages will provide your Personal Information collected as stipulated in Paragraph 1 to specified companies for which you wish to be employed, with your prior consent. The purpose of this is to provide information necessary for the company to determine whether or not to hire you and to contact you regarding your employment or non-acceptance. Leverages will enter into an agreement with the company to ensure that the company does not use your Personal Information for any purpose other than those listed above.

    3. Leverages will use your name and e-mail address from your Personal Information collected as stipulated in Paragraph 1 to send e-mails to you with your consent. E-mails will be sent for the following purposes:

    (1) To provide you with information about job openings that you can apply for on WeXpats. (2) To provide information about new WeXpats services or campaigns that are beneficial to you. (3) To provide you with information about housing, insurance, accommodation, transportation means and other information that may be useful to you when visiting or living in Japan related to using WeXpats. (4) To notify you of any changes in the content of WeXpats services. (5) To notify you about the creation of articles provided by WeXpats in order to recruit collaborators from among our users. (6) To request your cooperation in questionnaires regarding WeXpats' services or employment and working conditions in Japan for the purpose of providing you with information about WeXpats' services that is more suitable to your needs. (7) To request your cooperation in questionnaires regarding WeXpats' services or employment and working conditions in Japan for the purpose of tailoring the specifications of the website and other systems that provide WeXpats to better meet your needs.

    4. Leverages will use your name, telephone number and email address from your Personal Information collected as stipulated in Paragraph 1 to respond to your inquiries to us regarding WeXpats services.

    5. Leverages may use your name, address, and telephone number from your Personal Information collected as stipulated in Paragraph 1 to send you gifts and other special offers.

    6. Leverages may use your Personal Information collected as stipulated in Paragraph 1 to as statistical data in a format that does not identify your personal information, with your prior approval.

    7. Leverages may entrust all or part of the handling of your Personal Information collected as stipulated in Paragraph 1 to a third party to the extent necessary for us to achieve the purpose of use.

    Article 2: Cookies

    1. WeXpats may use cookies stored on your device. A cookie is a small text file that is stored on your device when you visit a website.

    2. Whenever Leverages intends to use a cookie stored on your device in WeXpats, we will indicate this to you beforehand and ask if you consent to this. We will only use cookies stored on your device for the following purposes if we have received your explicit consent:

    (1) To keep you logged in when you are browsing the WeXpats website so that we can display information customized to your needs (e.g., language selection, content placement). (2) To ask you to re-enter your password to log in after a certain period of time has passed so that you can safely use the WeXpats website. (3) To identify your activity history on the WeXpats website and to provide you with advertisements optimized according to your activity history on Facebook, Google, Yahoo!, and other advertiser services.

    3. Even if you have explicitly consented to the use of cookies as stipulated in Paragraph 2, you may disable Leverages' use of your cookies by selecting the option to disallow cookies in your browser settings when viewing the WeXpats website. In addition, with regard to the use of cookies in the services of advertisers from Item 3 of Paragraph 2, you can disable Leverages from using your cookies by following the procedures for opting out of cookies from the websites of each advertiser.

    4. If you do not consent to Leverages' use of cookies, you will not suffer any disadvantage regarding the use of WeXpats, except that you will not be able to use the functions listed in Items 1 and 2 of Paragraph 2.

    Article 3: Google Analytics

    1. The WeXpats website uses Google Analytics, a tool offered by Google, Inc. Google Analytics collects, records and analyzes your visit history, and for this purpose, may use cookies that Google stores on your device.

    2. Leverages does not collect any Personal Information about you when using Google Analytics. Leverages receives Google Analytics analysis information from Google, but this does not include your Personal Information.

    3. You may disable Google Analytics in the add-on settings of the browser on which you are browsing the WeXpats website.

    4. Google will manage your Personal Information collected by Google Analytics as stipulated in its Privacy Policy and Terms of Service. Refer to Google's Privacy Policy and Terms of Service for more information.

    ・Google Privacy Policy
    https://policies.google.com/privacy
    ・Google Analytics Terms of Service
    https://marketingplatform.google.com/about/analytics/terms/us/

    Article 4: Clarity

    1. The WeXpats website uses Clarity, a tool offered by Microsoft. Clarity collects, records and analyzes your behavior when you use a website, and for that purpose, Microsoft may collect your Personal Information.

    2. Leverages does not collect any Personal Information about you when using Clarity. Leverages receives Clarity analysis information from Microsoft, but this does not include your Personal Information.

    3. Microsoft will manage your Personal Information collected by Clarity as stipulated in its Privacy Statement. Refer to Microsoft's Privacy Statement for more information.

    ・Microsoft Privacy Statement
    https://privacy.microsoft.com/en-gb/privacy

    Article 5: Joint Use of Personal Information

    1. Leverages jointly operates WeXpats services with its group companies, and for that purpose, we may use your Personal Information collected on WeXpats jointly with our group companies. The types of Personal Information processed by the group companies in cases of joint use and the purposes for which it is processed are as stipulated in Article 1.

    【Click here for a list of group companies】

    2. When Leverages shares your Personal Information with its group companies as stipulated in Paragraph 1, and transfers your Personal Information outside of Japan, we will enter into an agreement with the group companies to ensure that the Personal Information is managed at a level equivalent to that of compliance with the Act on the Protection of Personal Information.

    3. Leverages will be responsible for the joint use of Personal Information as stipulated in Paragraph 1.

    Chapter 2: Management of Personal Information

    Article 6: Safety Management Measures

    1. Leverages will implement necessary and appropriate information security management for your Personal Information in order to comply with the Act on the Protection of Personal Information, GDPR and CCPA.

    2. Leverages will educate and supervise its employees to ensure that the information security management stipulated in Paragraph 1 is practiced even when the employees process your Personal Information.

    3. In addition to or along with the preceding two paragraphs, Leverages will implement these matters as a part of measures Leverages takes to manage Personal Information.

    Article 7: Contracting the Management of Personal Information

    Leverages may outsource the management of your Personal Information to another company for purposes such as the use of cloud services, system maintenance and management, and outsourcing delivery to a delivery company. In such cases, we will comply with the following:

    (1) Leverages will not select an outsourcing company which is not capable of properly managing your Personal Information at a level equivalent to or higher than that of Leverages.
    (2) Leverages will enter into a necessary and sufficient contract with the outsourcing company to ensure that your Personal Information is properly managed at a level equivalent to or higher than that of Leverages.
    (3) Leverages will supervise the outsourcing company to ensure that your Personal Information is properly managed at a level equivalent to or higher than that of Leverages.

    Article 8: Retention Period of Personal Information

    Leverages will retain your Personal Information only for the period of time necessary to achieve the purpose of processing as stipulated in Chapter 1. The specific retention period will be determined after taking into consideration the purpose of processing your Personal Information, the nature of your Personal Information, and the necessity to retain your Personal Information for legal or business purposes.

    Article 9: Providing Personal Information to Third Parties

    Leverages may provide Personal Information to a third party for any of the following reasons:

    (1) When required by law.
    (2) When it is necessary to protect the life, body, or property of an individual and it is difficult to obtain consent from the individual.
    (3) When it is particularly necessary to improve public health or promote the sound development of children, and it is difficult to obtain consent from the individual.
    (4) When it is necessary to cooperate with a national organization, a local government, or an individual or entity contracted by a national organization or local government to execute duties stipulated by laws and regulations, and Leverages determines that obtaining consent of the individual may impede the execution of such duties.
    (5) When a court of law, public prosecutor's office, police department, bar association, consumer affairs center, or an organization with similar authority requests disclosure of Personal Information.

    Chapter 3: Disclosure, etc. of Personal Data Possessed by Leverages

    Article 10: Disclosure, etc. of Retained Personal Data

    When Leverages is requested by you or your representatives for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, or erasure of retained Personal Data (hereinafter referred to as "Request for Disclosure, etc.") as stipulated in the Act on the Protection of Personal Information, Leverages will respond appropriately as stipulated in the Act on the Protection of Personal Information.

    Article 11: Necessary Procedures for Request for Disclosure, etc.

    1. Requests for Disclosure, etc. will be accepted only by postal mail, telephone or e-mail at the following contact information. In such cases, it is necessary to provide your or your representative's name and address in order for Leverages to send the designated request form by postal mail.

    【Contact Information】

    Shibuya Scramble Square, 24F, 25F,
    2-24-12 Shibuya, Shibuya-ku, Tokyo
    150-6190 Japan
    Customer Relations Office, Leverages Co., Ltd.
    E-mail: privacy@leverages.jp
    Phone number: 03-5774-1632

    *We will respond to inquiries on the following business day or later on Saturdays, Sundays, national holidays, New Year holidays, and other company holidays.

    2. Leverages will send by postal mail the designated request form to you or your representative when you make a Request for Disclosure, etc. as stipulated in Paragraph 1.

    3. Leverages will respond to Requests for Disclosure, etc. by mails or e-mails only when you or your representative send us a completed request form and identification documents as specified in Paragraph 4 by postal mail. Note that there is no fee charged for you or your representative to be notified of the purpose of use or disclosure of retained Personal Data.

    4. The identification documents to be sent by postal mail as stipulated in Paragraph 3 are as follows:

    【Identification Documents】

    1. For the Owner of the Personal Information

    When making a Request for Disclosure, etc., enclose a copy of one of the following identification documents. Note that unless your address is listed as "the same as" your permanent domicile, erase your permanent domicile by blacking it out, etc.

    (a) Driver's license
    (b) Health insurance card
    (c) Basic resident card or My Number Card
    (d) Pension booklet
    (e) Alien registration card
    (f) Passport

    2. For representatives

    If the person making the Request for Disclosure, etc. is a representative, submit the following identification documents (copies) in addition to the documents in Item (1) above. Make sure that the documents show your current address, and black out the part of your permanent domicile.

    (a) Legal Representative
    ・Documents confirming the legal representative's right (such as a copy of the health insurance card that clearly states a person in parental authority)
    ・Documents confirming the legal representative's identity (such as a copy of the legal representative's driver's license and health insurance card)

    (b) Authorized Representative
    ・Power of attorney
    ・Documents to confirm the identity of the representative (such as a copy of the representative's driver's license or health insurance card)

    Article 12: Court of Competent Jurisdiction

    The Tokyo District Court or the Tokyo Summary Court is the exclusive court of first instance for any and all disputes related to the procedures described in this Chapter.

    Chapter 4: Personal Data of the Customers in the EEA

    Article 13: GDPR Compliance

    Leverages will comply with the GDPR when processing your Personal Data if you reside in the EEA or are otherwise a data subject under the GDPR (hereinafter referred to as "Customers in the EEA").

    Article 14: Legality of Processing of Personal Data

    1. Leverages will provide information regarding your nationality, address, date of birth, telephone number, personal background, qualifications held, and Japanese language ability to specified companies where you wish to be employed, as stipulated in Paragraph 2 of Article 1. WeXpats' primary service is to match you with employers in Japan to help you get hired. In order to successfully match you with a company, it is necessary to provide that company with the information necessary to determine whether or not to hire you and to contact you regarding employment, and therefore the processing of such Personal Data is legal under Article 6(1)(b) of the GDPR.

    2. Leverages will process your name and email address for the purpose of providing you with information via email as stipulated in Paragraph 3 of Article 1. The sending of such emails is necessary to improve the quality of WeXpats' services, to enhance your convenience, and to encourage you to use WeXpats by enhancing your job search, and is in your best interest. In addition, when we send an e-mail to you, it will only be done with your prior consent, so the impact on you will not be greater than prioritizing the benefits we receive. Such processing of Personal Data is necessary for the legitimate interests pursued by the controller, and is therefore lawful under Article 6(1)(f) of the GDPR.

    3. Leverages will use your name, telephone number, and e-mail address for the purpose of responding to your inquiry as stipulated in Paragraph 4 of Article 1. We process your Personal Data because it is necessary for the performance of a contract with you, and in order to take steps at your request before entering into a contract with you. The processing of your Personal Data is considered lawful under Article 6(1)(b) of the GDPR.

    4. Leverages will process your name, address and telephone number for the purpose of sending you gifts and other special offers as stipulated in Paragraph 5 of Article 1. Providing you with special offers is necessary to promote the use of WeXpats' services to you. This allows you to receive the special offers, and the disadvantage you suffer is limited to the provision of your Personal Data to the delivery company (when contracting a delivery company, we will comply with the stipulations of Article 7). Such handling of Personal Data is lawful in accordance with Article 6(1)(f) of the GDPR.

    5. Leverages uses cookies on the customer's device as stipulated in Article 2. When using cookies, we will only do so after clearly indicating this to you in advance and obtaining your explicit consent. In addition, you can easily refuse to allow Leverages to use cookies at any time by using the methods listed in Paragraph 3 of Article 2. If you refuse the use of cookies, you may still continue to use WeXpats services without difficulty. Such processing of Personal Data is lawful in accordance with Article 6(1)(a) of the GDPR.

    6. Leverages may provide your Personal Data to third parties as stipulated in Article 9. The reasons listed in Article 9 are those for which we are obligated by Japanese law or socially required to comply when providing Personal Data. Leverages may also provide Personal Data of Customers in the EEA to third parties to the extent that such provision is lawful in accordance with Article 6(1)(f) of the GDPR, as stipulated in Article 9.

    7. Leverages may process your Personal Data or your representative's Personal Data in connection with a Request for Disclosure, etc. as stipulated in Chapter 3 (including requests stipulated in Article 22). Such processing of Personal Data is necessary for Leverages to properly comply with its legal obligations as stipulated in the Act on the Protection of Personal Information, and does not impose any disadvantage to you or your representative beyond the scope of necessity. Such processing of Personal Data is lawful in accordance with Article 6(1)(f) of the GDPR.

    Article 15: Joint Managing

    1. Leverages may jointly manage the Personal Data of Customers in the EEA with our group companies, as stipulated in Article 5. In such cases, an agreement between Leverages and the group company will stipulate that Leverages will comply with the manager's obligations under the GDPR and that Leverages will be the point of contact for customer communications.

    2. Personal Data of Customers in the EEA will not be transferred outside of Japan, regardless of the stipulations in Paragraph 2 of Article 5. The transfer of Personal Data within Japan does not violate the GDPR due to the existence or absence of an adequacy decision by the Commission.

    Article 16: Processor

    Leverages may allow a processor to process the Personal Data of Customers in the EEA as stipulated in Article 7. In doing so, we will comply with the following:

    1. We will not select as a processor that is unable to guarantee that it will manage the Personal Data of Customers in the EEA through information security management at a level equivalent to or higher than that required by the GDPR.

    2. There will be a stipulation in the contract between Leverages and the processor that the processor guarantees to manage the Personal Data of Customers in the EEA with information security management at a level equivalent to or higher than that required by the GDPR.

    3. There will be a stipulation in the contract between Leverages and the processor that the processor must obtain our prior written consent before contracting out the management of the Personal Data of Customers in the EEA to another party.

    4. Leverages will oversee the processor to ensure that the processor continues to manage the Personal Data of Customers in the EEA with information security management at a level equivalent to or higher than that required by the GDPR, and will require the processor to pledge in the contract to be subject to such oversight.

    Article 17: Right to Access Personal Data

    You have the right to confirm with Leverages whether or not we are processing Personal Data that relates to you. In addition, if we are processing Personal Data, you have the right to access certain information such as the purpose and category of the Personal Data (Article 15 of GDPR).

    Article 18: Right to Rectification and Erasure of Personal Data

    You have the right to have us rectify any inaccurate Personal Data that concerns you without undue delay (Article 16 of the GDPR). You also have the right to have Leverages erase your Personal Data without undue delay if the processing of your Personal Data is no longer necessary, if you withdraw your consent to the processing of your Personal Data on the basis of Article 6(1)(a) of the GDPR, or if certain other requirements are met (Article 17 of the GDPR).

    Article 19: Right to Restriction of Processing

    You have the right to have Leverages restrict the processing of your Personal Data when there are doubts about the accuracy of the Personal Data or when certain other requirements are met (Article 18 of the GDPR).

    Article 20: Right to Object to Processing of Personal Data

    You have the right to object to the processing of Personal Data concerning you if certain requirements are met (Article 21 of the GDPR).

    Article 21: Right to Data Portability

    You can receive Personal Data concerning you in a structured, commonly used, machine-readable format if certain requirements are met. You also have the right to have your Personal Data transferred to another controller without hindrance from Leverages (Article 20 of the GDPR).

    Article 22: Contact Point of Controller

    The contact information for Customers in the EEA to contact Leverages is the same as set forth in Paragraph 1 of Article 11. In addition, the procedures required for Customers in the EEA to exercise the rights stipulated in Articles 17 through 21 are the same as those stipulated in Article 11.

    Article 23: Not Being Subject to Automated Decision-Making

    Leverages will not cause or materially impact any legal effect on you by making a decision based solely on automated processing of your Personal Data (Article 22 of the GDPR).

    Article 24: Right to Object to the Supervisory Authority

    If you object to the processing of your Personal Data by Leverages, you may file an objection with the supervisory authority in your place of residence, place of work, or the GDPR member state where the violation occurred.

    Chapter 5: Personal Data of Customers in California

    Article 25: Compliance with CCPA

    Leverages will comply with the CCPA when processing Personal Information of customers residing in California and other customers who are considered consumers under the CCPA (hereinafter referred to as "Customers in California").

    Article 26: Use of Cookies

    In the event that the cookie information stored on your device in the State of California is provided to an advertiser as stipulated in Item 3, Paragraph 2, Article 2, the advertiser may be considered a service provider under the CCPA. Advertisers have entered into agreements with Leverages stipulating that they will use cookie information only to the extent necessary to achieve the purpose of distributing the Leverages' advertisements, and will not use cookie information beyond that scope.

    Article 27: Joint Use of Personal Information of Customers in California

    1. In the joint use of Personal Information as stipulated in Article 5, group companies may be considered a service provider under the CCPA.
    2. In the joint use of Personal Information as stipulated in Paragraph 1, the group company will receive and use the Personal Data of Customers in California disclosed by Leverages to the extent necessary to achieve the purpose of jointly operating the business of WeXpats with Leverages.
    3. In the event that Leverages discloses the Personal Data of Customers in California to group companies for the joint usage listed in Paragraph 1, we will enter into an agreement with the group company to ensure that the group company does not use the Personal Data beyond the scope necessary to achieve the purpose of jointly operating WeXpats' business with Leverages.

    Article 28: Outsourcing the Management of Personal Information of Customers in California

    When outsourcing the management of Personal Information as stipulated in Article 7, the outsourcing company will not be considered a third party under the CCPA. This is because Leverages will only use the Personal Information of Customers in California based on an agreement that includes (1) the sale of Personal Information, (2) the processing of Personal Data for purposes other than the provision of the services specified in the outsourcing agreement, and (3) the certification that it will not process Personal Information other than in a direct business relationship.

    Article 29: Right to Request Disclosure

    1. Customers in California have the right to request that Leverages discloses any Personal Information that it obtains, uses, discloses, or sells.
    2. The procedures for exercising the right in Paragraph 1 are the same as those stipulated in Article 11.
    3. The following is a list of the categories of Personal Information that we obtain from Customers in California.

    List of categories of Personal Information
    ・Identifiers: Name, address, e-mail address, cookie information, and the numbers listed on driver's license, health insurance card, basic resident card, My Number Card, pension booklet, alien registration card, and passport.
    ・Categories of Personal Information as stipulated in California Civil Code 1798.80(e): Telephone numbers, information regarding education, information regarding employment, background information.
    ・Information on activities on the Internet and other electronic networks: Browsing history, search history.
    ・Professional or employment-related information.
    ・Other information: Profile photo, nationality, date of birth, qualifications held, Japanese language ability.
    4. All Personal Information that Leverages obtains from Customers in California is obtained from the actual consumer.

    Article 30: Right to Request Deletion

    1. Customers in California have the right to request the deletion of their Personal Information held by Leverages.
    2. The procedures for exercising the rights in Paragraph 1 are the same as those stipulated in Article 11.

    Article 31: Right to Opt-Out of Sales

    Customers in California have the right to request that Leverages not sell their Personal Information. More importantly, we do not make any sales that are subject to this right.

    Article 32: Right to be Free from Discrimination

    Customers in California will not be subjected to discriminatory treatment by Leverages because they have exercised their rights stipulated by the CCPA.

    Article 33: Contact Point for Inquiries

    The contact point for Customers in California, whose Personal Data is processed by Leverages, to make inquiries regarding the Leverages' Privacy Policy or handling of private matters is as listed in Paragraph 1 of Article 11.

    Chapter 6: Other

    Article 34: Revision of the Privacy Policy

    When we revise this Privacy Policy, we will announce the revision, date of revision and the revised content on the WeXpats website or via e-mail.

    Article 35: Language of the Original Text

    This Privacy Policy is provided in Japanese as the original text, and translated into other languages according to the region in which you reside.

    Date of Latest Revision: February 13, 2024

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